DCIT,CIRCLE-17(1), HYD, HYDERABAD vs. DR. REDDY'S LABOURATORIES LTD., HYD, HYDERABAD

In the result, appeal of the revenue is dismissed

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2006-07

144C(5) on 30.09.2010 and the assessing officer based on the directions given by the DRP, passed the assessment order on 01.11.2010. Further, the Assessing Officer initiated penalty proceedings u/s 271(1)(c) of the Act stating that the assessee had made wrong claims under different heads and levied penalty of Rs.34,65,20,080/- which is stated

APACHE FOOTWEAR INDIA PRIVATE LIMITED,MAMBATTU VILLAGE vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CIRCLE-1(1), TIRUPATI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

Section 271 (1) ( c) of the act of the even date. Issue that arises is Whether draft assessment order accompanied with [1] Notice of Demand, [2] tax Computation sheet and [3] Show Cause Notice for penalty u/s 271 (1) (C) of the act, can it be considered as draft assessment order or a final assessment order

BS LIMITED,HYDERABAD vs. ASST.COMISSIONER OF INCOME TAX, CIRCLE-2(3), HYDERABAD

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri D. Manmohan & Shri S. Rifaur Rahmanassessment Year: 2013-14

144C(1) of the Act by issuing the notice of demand u/s. 156 of the Act & penalty notices u/s. 271(1)(c) and 271AAB along with Draft assessment order dated 30.12.2016, which tantamount to passing of Final Assessment Order. 2. Erred in making adjustment u/s. 92CA(3) of the Act for Rs. 4,79,143/- in respect of transaction

GSS INFOTECH LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

144C(1) of the Act. The Ld. AO erred in not appreciating the fact that issuance of notice of demand U/s. 156 of the Act and Penalty notices u/s. 271AA, 271BA and 271(1)(c) along 2. with the draft assessment order dated 15.12.2017, would tantamount to passing of Final Assessment Order. The Ld.TPO/DRP erred in rejecting

GSS INFOTECH LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD-2(2), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt. P. Madhavi Devi & Shri A. Mohan Alankamony

144C(1) of the Act. The Ld. AO erred in not appreciating the fact that issuance of notice of demand U/s. 156 of the Act and Penalty notices u/s. 271AA, 271BA and 271(1)(c) along 2. with the draft assessment order dated 15.12.2017, would tantamount to passing of Final Assessment Order. The Ld.TPO/DRP erred in rejecting

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, the assessee appeal is allowed

Bench: Shri Inturi Rama Rao & Shri Laliet Kumarvs. Dy. Commissioner Of M/S. Hyundai Motor India Engineering Pvt. Ltd., Income Tax, Circle Hyderabad. 2(2), Hyderabad. Pan Aabcjh7867C Appellant Respondent Appellant By : Shri H. Srinivasulu, Adv. Respondent By : Shri Yvst Sai, Cit-Dr. Date Of Hearing : 27.07.2022. Date Of Pronouncement : 29.07.2022. O R D E R Per Shri Inturi Rama Rao, A.M. : This Is An Appeal Filed By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-2, Hyderabad Dt.05.12.2019 For Assessment Year 2015-16. 2. The Assessee Raised The Following Grounds Of Appeal :

penalty proceedings u/s. 271(1)(c) of the Act. 3.6 Being aggrieved by the above draft assessment order along with demand notice, the assessee filed an appeal before the learned CIT (Appeals) challenging inter alia the validity of assessment order on the ground that the assessee is an eligible assessee, within the meaning of provisions of section 144C

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -2(1), HYDERABAD

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumar

Section 92CA of the IT Act, directions given by DRP u/s 144C(5) of the Act and “Give Effect to Directions u/s 144C order of the TPO dt.19.03.2021, the final assessment order u/s 143(3) r.w.s. 144C(13) of the Act was passed and the total income of the assessee was assessed at Rs.49,99,97,796/-. Thereafter

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

Bench: Us:

penalty proceedings under section 270A of the Act by alleging that there is under reporting of income by the Appellant.” 3. Apart from that the assessee company has filed before us letters dated 14.07.2023, 21.09.2023 and 22.04.2025, wherein it has raised additional grounds of appeal, which reads as under: Filed on 14.07.2023: “1. On the facts and circumstances

COMM VAULT SYSTEMS (INDIA) PVT.LTD., HYD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYD, HYDERABAD

In the result, assessee’s appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahm/S. Comm Vault Systems Vs Dy. Commissioner Of Income (India) Private Limited Tax, Circle 1(2) Hyderabad Hyderabad Pan: Aaccc 3708 L (Appellant) (Respondent)

144C of the Act dated 21.12.2015 in bringing to tax the adjustment proposed by the TPO u/s 92CA(4) of the I.T. Act and the objections of the assessee have been rejected by the DRP. 2. Brief facts of the case are that the assessee company, engaged in the business of software development services & distribution of parent company’s products

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumar

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumar

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

MADHUCON PROJECTS LTD, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

Bench: Shri R.K. Panda & Shri Laliet Kumar

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH PRIVATE LIMITED),HYDERABAD vs. ACIT., CIRCLE-16(2), , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

ACIT, CIRLCE-5 (1), , HYDERABAD vs. MARKET TOOLS RESEARCH PRIVATE LIMITED , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH P. LTD.,),HYDERABAD vs. ACIT, CIRLCE-16(2), , HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

ACIT., CIRCLE-5(1) , HYDERABAD vs. MARKET TOOLS & RESEARCH PRIVATE LIMITED, HYDERABAD

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

FACEBOOK INDIA SERVICES PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-17(1), HYDERABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2014-15 Facebook India Online Services Vs. The Deputy Commissioner Private Limited, Of Income Tax, 12Th Floor, Building No.20, Circle – 17(1), Unit 1203 & 1204, Hitech City, Hyderabad. Madhapaur, Hyderabad. Pan : Aabcf5150G. (Appellant) (Respondent) Assessee By: Shri Dhanesh Bafna & Chandni Shah Revenue By: Shri Rajendra Kumar – Cit-Dr Date Of Hearing: 20.07.2022 Date Of Pronouncement: 19.09.2022

144C(13) of the Income Tax Act, 1961 (in short, “the Act”) raising the following grounds : 2 “Transfer pricing grounds - IT enabled services segment 1. On the facts and in the circumstances of the case and in law, the Learned Dispute Resolution Panel ('Ld. DRP') erred in upholding the action of the Ld. AO / Transfer Pricing Officer

PALRED TECHNOLOGIES LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

Appeal is partly allowed for statistical purposes

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahuassessment Year: 2008-09

144C r.w.s. 254 of the Act. The assessee has raised the following substantive grounds: “TRANSFER PRICING MATTERS - Relating to determination of Arm's Length Price (" ALP") in respect of provision of software services to Associated Enterprises (" AEs") Based on the facts and circumstances of the case and in law, the learned Assessing Officer (" AO") / learned Transfer Pricing Officer